News & analysis of the United States Court of Appeals for the Third Circuit, by Matthew Stiegler

Supreme Court summarily reverses Third Circuit on qualified immunity

The Supreme Court today summarily reversed a 2014 Third Circuit ruling in a prisoner-rights suit. A divided CA3 panel had held that prison officials were not entitled to qualified immunity in an Eighth Amendment suit brought by the estate of a prisoner who had committed suicide. The Supreme Court, in a unanimous per curiam opinion, reversed and held that there was no clearly established right to proper implementation of adequate suicide prevention protocols. USSC assumed that CA3 was correct that circuit precedent can clearly establish a right when that precedent conflicts with other circuits, but ruled that CA3 was wrong about what its own precedent held.

The case was Barkes v. First Correctional Medical in the Third Circuit (circuit opinion here, my summary here), and Taylor v. Barkes in the Supreme Court (opinion here).